Agricultural Land Sale Proceeds: Section 148 Reassessment Notice Quashed as Mere Change of Opinion on Section 54B Deduction

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....The HC quashed the reassessment notice issued under section 148, finding it impermissible as a mere change of opinion rather than based on new information. The authorities sought to reopen assessment regarding the taxpayer's section 54B deduction claim, despite having previously considered this issue during the original section 143(3) assessment. The court held that reopening requires "reasons to believe" with direct nexus to new tangible material, not merely alleging inadequate inquiry by the previous Assessing Officer. Since the taxpayer had fully disclosed all relevant documents during the original assessment, the reopening was invalid in law. Judgment favored the assessee.....